Item 1B. Unresolved Staff Comments
Item 1B. Unresolved Staff Comments
None.
Item 1C. Cybersecurity
Cybersecurity Risk Management and Strategy
We have developed and implemented a cybersecurity
risk management program intended to protect the confidentiality, integrity, and availability of our critical systems and information.
We have implemented a number of security measures
designed to protect our systems and data, including firewalls, antivirus and malware detection tools, patches, log monitors, and routine
back-ups,. In addition, we have continued our efforts to migrate our platforms to cloud-based computing, which is designed to further
strengthen our security posture.
Our cybersecurity risk management program is integrated
into our overall enterprise risk management program and shares common methodologies, reporting channels, and governance processes that
apply across the enterprise risk management program to other legal, compliance, strategic, operational, and financial risk areas.
Our cybersecurity risk management program includes
the following:
●
the use of external service providers , where appropriate,
to assess, test, or otherwise assist with aspects of our security controls; and
●
cybersecurity awareness training of our employees,
incident response personnel, and senior management
There can be no assurance that our cybersecurity
risk management program and processes, including our policies, controls or procedures, will be fully implemented, complied with or effective
in protecting our systems and information.
Cybersecurity Governance
Our Board considers cybersecurity risks as part of
its risk oversight.
The Board oversees management’s implementation
of our cybersecurity risk management program and receives updates on the cybersecurity risk management program from management at least
annually. In addition, management updates the Board regarding any material or significant cybersecurity incidents, as well as incidents
with lesser impact potential as necessary.
Ongoing Risks
We have not experienced any material cybersecurity
incidents. We have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents,
that have materially affected us, including our operations, business strategy, results of operations, or financial condition.
Incident Response and Assessment Policies and
Procedures
We align with industry-standard cybersecurity frameworks
designed to protect the company and customer data from unintentional disclosure, cybersecurity events, and other threats of all severity
levels. As part of our alignment with these frameworks we are in the process of implementing a Cybersecurity Incident Response Plan that
outlines actions to be taken after identifying a suspected information security breach and the people responsible for managing those
actions. Additionally, this plan will outline communication responsibilities during incidents of all severity levels.